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This approach would ensure that the value of the HEBA itself cannot exceed 5 percent of national assignable per capita expenditures expressed as a single value using the ACO's BY3 enrollment proportions, similar to the cap applied to the regional adjustment under 425.656(c)(3) and the cap applied to the prior savings adjustment under 425.658(c)(1)(ii)

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Different CFs would result in different direct PE scaling adjustments, but this has no effect on the final direct cost PE RVUs since changes in the CFs and the associated direct scaling adjustments offset one another

Counselling and medication can more than double a tobacco users chance of successful quitting